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                              May 10, 2022

       Yu Yang
       Chief Executive Officer
       Qiansui International Group Co. Ltd.
       7th Floor, Naiten Building, No. 1
       Six Li Oiao, Fentai District
       Beijing, China 100161

                                                        Re: Qiansui
International Group Co. Ltd.
                                                            Form 10-K for the
Year Ended December 31, 2020
                                                            Filed September 23,
2021
                                                            File No. 000-54159

       Dear Mr. Yang:

              We have reviewed your May 5, 2022 response to our comment letter
and have the
       following comments. In some of our comments, we may ask you to provide
us with information
       so we may better understand your disclosure.

              Please respond to these comments within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe our
       comments apply to your facts and circumstances, please tell us why in
your response.

              After reviewing your response to these comments, we may have
additional
       comments. Unless we note otherwise, our references to prior comments are
to comments in our
       April 25, 2022 letter.

       Form 10-K for the Year Ended December 31, 2020

       Item 1. Business, page 3

   1.                                                   We note your response
to comment 3 and partially reissue our comment. While we
                                                        note that you are a US
company with no operating PRC subsidiaries, we also note that
                                                        your principal
executive offices are located in China. In light of your location in China,
                                                        please revise to
disclose each permission that you are required to obtain from Chinese
                                                        authorities to operate
and issue securities to foreign investors. We also note the current
                                                        disclosure that you are
not required to obtain such permissions. Please disclose how you
                                                        reached such a
determination (e.g. internal legal analysis, opinion of external counsel or
                                                        other advisor, etc.).
Please also clarify bullet 3 of the proposed disclosure that as of the
                                                        date of the filing you
will not have received or were denied such permissions by any PRC
 Yu Yang
Qiansui International Group Co. Ltd.
May 10, 2022
Page 2
      authorities. To the extent you were denied permissions, provide clear
disclosure of each
      permission denied. Lastly, please address the consequences to you and
your investors if
      you do not receive or maintain approvals where you inadvertently conclude
that such
      approvals are not required, or applicable laws, regulations, or
interpretations change and
      you are required to obtain approval in the future.
Item 1. Business
Part I, page 3

2.    We partially reissue comment 6. Please disclose prominently at the
beginning of Part I
      that your principal executive offices are located in China, a majority of
your executive
      officers and/or directors are located in or have significant ties to
China and that you will
      not restrict potential target companies to any specific business,
industry or geographical
      location and, thus, may acquire a company that may be based in China or
Hong Kong.
      Please revise your disclosure at the onset of Part I to also address how
recent statements
      and regulatory actions by China   s government, such as those related to
data security or
      anti-monopoly concerns may impact post business combination the company
s ability to
      conduct its business, accept foreign investments, or list on an U.S. or
other foreign
      exchange.
      You may contact William Demarest, Staff Accountant at 202-551-3432 or
Shannon
Menjivar, Accounting Branch Chief at 202-551-3856 if you have any questions.



                                                             Sincerely,
FirstName LastNameYu Yang
                                                             Division of
Corporation Finance
Comapany NameQiansui International Group Co. Ltd.
                                                             Office of Real
Estate & Construction
May 10, 2022 Page 2
cc:       Daniel Luciano
FirstName LastName